Hartlepool - Planned Compliance Inspection

Site: Hartlepool

IR number: 18-034

Date: April 2018

LC numbers: 36

Executive summary

Purpose of Intervention

The purpose of this intervention was to undertake compliance inspection activities at EDF Energy Nuclear Generation Limited’s (NGL) Hartlepool power station, in line with the ONR’s inspection programme contained in the Hartlepool Integrated Intervention Strategy (IIS) for 2018/19.

Interventions Carried Out by ONR

In my capacity of nominated site inspector for Hartlepool Power Station, I performed an intervention to examine the licensee’s compliance arrangements with regard to nuclear site licence condition (LC) 36, Organisational Capability.

The intervention was performed in line with ONR’s guidance requirements (as described in our technical inspection guides) in the areas inspected.

In addition to the LC36 compliance inspection, I also met with Independent Nuclear Assurance staff, accompanied ONR internal hazards specialists on a station walk down, met with a safety representative and undertook two system-based walk downs.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable - no system based inspections were completed during this intervention.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

The key findings of this intervention with respect to LC36 are:

NGL staff interviewed were able to articulate the requirements of the corporate arrangements to my satisfaction.

Based on the sample I took, the Management of Change (MoC) process is well understood and implemented in line with corporate arrangements.

I identified some opportunities for improvement; including:

Contingency measures including more detail,

Improving ‘local knowledge’ capture,

Use of a handover plan considered for all changes where one person replaces another, even on a temporary basis.

The December 2017 nuclear baseline is still awaiting approval, though baseline numbers are largely unchanged from the December 2016 revision, thus reducing the immediate nuclear safety impact.

The station has a forward looking plan (to 2024) for management of retirees and if their role is linked to the nuclear baseline, thus helping to ensure a complete baseline and preserve knowledge.

The annual nuclear baseline review is not used as a critical, technical review of the baseline numbers, which does not align the relevant Nuclear Industry Code of Practice.

A regulatory issue has been raised to track progress on this matter.

Whilst it does not currently present an immediate nuclear safety detriment, as the station moves into end of life, a fully justified nuclear baseline will become a key foundation to a healthy MoC process.

Conclusion of Intervention

Overall, I judge that the standard of compliance was consistent with relevant good practice and I am satisfied that the licensee is complying with its legal duties. Items for potential improvement were fed back to the station; one regulatory issue was raised to track progress with regard to a periodic, critical and technical review of the nuclear baseline numbers. I have awarded the following inspection rating: LC36 - GREEN.

There are no findings from this inspection that could undermine nuclear safety at this time. At present, no additional regulatory action is needed over and above the planned interventions at Hartlepool Power Station.